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The Form That Lets You Say, ‘More Forms, Please’

Standard Form 152 is not a famous federal form like the Internal Revenue Service’s 1040. But for more than four decades, it has been assigned the job of standing sentry over other federal forms.

Agencies that want to create, kill or amend federal forms often have to fill out an SF152, also known as a “Request for Clearance or Cancellation of a Standard or Optional Form,” or file another form just like it.

In other words, the SF152 is a federal form that begets other federal forms — a dispenser from which red tape first flows.

New York does not have a counterpart for the SF152, and officials say they do not feel the same pressure to have a centralized mechanism to control the creation of forms. But in Washington, it has become a fixture as bureaucrats try to follow the dictates of legislation like the Paperwork Reduction Act of 1980.

Despite such legislation, the arrival of the Internet and the earnest nature of the SF152’s mission, neither it nor its gate-keeping counterparts have done much to slow the swelling tide of federal forms.

Last year, Americans spent nearly 10 billion hours [pdf] filling out more than 8,000 different government forms and other official requests for information tracked by the federal budget office. That compares with roughly one billion hours spent on similar paperwork in 1981, which in hindsight looks to have been a refreshingly uncomplicated time.

“Jumping up to 10 billion in 20 years’’ is no small feat, said David S. Cordray, a statistics professor at Vanderbilt University, who oversaw reports on government bureaucracy as a former federal official. “I wish the stock market had done that.’’

Some of the increase is attributable to changes in methodology. But government officials are hard-pressed to deny the obvious. “The general trend over the years has been an expansion of total burden hours,’’ agreed Tom Gavin, deputy associate director for Strategic Planning and Communications in the White House’s Office of Management and Budget.

Many of the forms come courtesy of new laws and regulations, and many of them, individually, have their defenders. Other new forms are the product of technological change, such as Standard Form 5510, [pdf] or an “Authorization Agreement for Preauthorized Payments,’’ which was devised by the Department of Treasury to—-

“I’m definitely unhappy about the proliferation of forms,” said Diana Furchtgott-Roth, a senior economist in three Republican administrations. “But that’s why you need someone to oversee the creation of forms. Otherwise, these agencies will be issuing forms left, right and center.’’

These days, that someone is likely to be a member of the “Forms Policy and Management Team” embedded inside at the United States General Services Administration, which processes all SF152s. Each is two pages long and requires agencies to answer 27 questions and provide a “supporting statement’’ to justify the need for a brand-new form.

The SF152 regulates only what are known as “standard” or “optional” forms, a mere portion of the federal form universe. Just how many standard or optional forms exist is something of a mystery. No one contacted at the “Forms Policy and Management Team” would say.

Agencies have great latitude to create their own forms, of course. As a result, there appear to be thousands and thousands of “agency forms,” of which the I.R.S.’s 1040 [pdf] is but one example.

Some agencies also have their own 152-like forms, intended to ensure that the forms they mint and print for internal purposes also pass muster. The General Services Administration calls its version a “Request for Forms Management Services’’ — Form 2192 [pdf] for short. The Nuclear Regulatory Commission has its Form 160, and the National Institute of Standards and Technology has its Form 66.

Since the days of Jimmy Carter, both Democratic and Republican presidents have vowed to curb the paper-shuffling. Printers, who do the heavy lifting when bureaucrats dream up new forms, say that Republicans tend to spawn defense-related forms while Democrats breed those tied to social programs.

“As a Republican, I love it when the Dems run the White House and Congress,’’ said William A. Gindlesperger, a consultant to the commercial printing industry, “because they love to print.”

When it passed the Government Paperwork Elimination Act in 1998, Congress encouraged the use of online forms. The law has been credited with reducing paperwork, but not forms or the bureaucracy involved in processing them.

“Paradoxically, the ability to have the forms electronically has increased the number of forms and made them longer,” Ms. Furchtgott-Roth said, “because if you don’t have to print them, it’s a lot easier to require someone to do it.’’

The General Services Administration rolled out SF152 in May 1967, back when it inherited responsibility for standard and optional forms.

Agencies that fill it out must furnish the name of a designated “standard and optional forms liaison representative’’ and an alternate. If the form will be used to collect information, or will be the basis of general purpose statistics, agencies must obtain a control number and clearance from the Office of Management and Budget.

To secure that, an applicant must estimate how great a burden the new form might impose on the public by gauging the expected number of users, the time it might take to fill out the form out and the frequency with which the information is collected each year.

Completed SF152’s get sent to Room 2218 at General Services Administration headquarters in Washington — ideally, the agency asks, 60 days “prior to planned implementation.”

Agency officials say they screen for duplication, need and ease of use, and submissions that meet those tests generally advances. Attempts to correct spelling or grammatical mistakes do not necessitate the filing of an SF152. Design changes do.

Final approval comes when Reza Motamedamin, the G.S.A.’s Standard Forms/Optional Forms management officer, signs on Line 16a. General Services Administration officials declined over a period of weeks to make Mr. Motamedamin available to answer several other basic questions about the SF152, one of which is capable of keeping Andy Rooney up at night.

If the SF152 is the mother of all forms, what gave birth to the SF152?

This is an amusing, but also silly and misleading, post, and not just because it’s been more than 20 years since 1981. For one thing, the Dow was at 838.74 on 1/1/1980, and 11,358 on 1/3/2001 – an increase of much MORE than 10 times, so if they had anything to do with one another, you might suppose the proliferation of federal forms has led to economic growth. But perhaps the better lesson is that Prof. Corday’s views aren’t quite so authoritative.

Shouldn’t the question be whether we are getting more welfare (meaning well-being) from federal efforts, not whether that’s being accomplished through paperwork? Perhaps appropriate distribution of federal benefits requires more paperwork than was used thirty years ago; perhaps better forms is leading to better results. That does not fit into the make-fun-of-bureaucrats line that ignorant conservatives have been pushing for fifty years, and that the media now enjoys embracing to feel as though it gives ignorant conservatives a fair shake.

As a retired bureaucrat I’m always glad to see the Times devoting space to the essential bureaucratic tools. By conflating two separate processes (GSA and OMB) the article inadvertently points to a problem: the government has not updated its approach to forms. Specifically the SF-152 is a carryover from the days of snail mail, when printed forms were the key to government work. It covers only forms used by two or more agencies, whether it’s strictly internal, or whether they obtain data from the public. So an agency can create its own form without GSA clearance. (The idea was to save each agency from reinventing the wheel.)

But that’s true only if the agency’s employees are the ones using the form. If the poor bureaucrat needs the public to provide data, she has to get approval, not from GSA, but from OMB. That’s the source of the estimate of 10 billion hours. And the reason why the IRS-1040 has an OMB approval number in the top corner and why there’s some unreadable fine print giving the estimated time to complete.

But neither the GSA approval process nor the OMB process has been reconsidered in the light of the Internet and e-government. Agencies are reinventing the wheel all across the Net.

Perhaps appropriate distribution of federal benefits requires more paperwork than was used thirty years ago; perhaps better forms is leading to better results.

Or “perhaps” not.

Making fun of bureaucrats and bureaucracy has not traditionally been the exclusive purview of “ignorant conservatives” ; blind endorsement of said bureaucracy *has* traditionally been the exclusive domain of foolish liberals. It just doesn’t always hold true in reverse.

The only government form worth anything is that one that mentions something about life, liberty, and the pursuit of happiness. The rest are mostly trying to get in the way of those things.

I work for an import/export company where I regularly interact with US Customs, FDA, FCC, ATF, Fish and Wildlife, USDA and the Department of Commerce.

In addition to the amount of forms that have to be completed, each office of each agency has their own quirks in handling these documents. US Customs’ office in Buffalo, NY, for example, requires certain documents to be placed in blue folders while another office in Port Huron, MI requires that same document to have a special coversheet.

Our government agencies seem to have a pathalogical hatred torwards e-mail. Any transmission of documents must be in the form of fax or courier service. People are amazed that I send upwards to 10 faxes a day. For most people, they may send this amount in a year.

Thank you Allison Cowen (#5) for your kind words and taking the time out to fill out your NY Times.com “commentator” form which commented on my observation about filling out a NYTimes.com form to comment about the feds requiring one to fill out a form to receive a government form or to stop receiving a government form!

(My apologies Allison for the redundency- I could not stop myself-LOL!)

As a retired Federal civil servant I can say a couple of things about the nature of forms. Please note that I am writing about the offices that make up the parts of an agency or department. It might be called an agency form, but it is some office in the agency that gave birth to and nurtures the form. And the agenda of that office is not the same as the agenda of the overall organization, be it a public or private corporation. Even if the organization wants to cut personel, every office wants to grow and have the cuts come from the other parts. You can be quite sure no office manager at GM thinks that cuts should come from his/her office.

The above forms the basis for understanding why new forms are born and few ever die. First, agency offices hoard information-generating forms for the same reason some people hoard stuff: You never know when you might need it. Better safe than sorry. Also, if you eliminate a form, your office has less work to do, which endangers your level of staffing and your budget. It even sends a message that your office might not even be that important. No manager, public or private, wants to do that. The end result is that a Secretary, Agency Director, or CEO is fighting his own organization all the way in any attempt to eliminate paperwork.

Here is a suggestion for reducing the burden if not the number of forms. Form an office, which reports directly to the President, that collects and reviews all governmental forms and breaks them down into standardized parts so that the respondent can assemble a new form from parts of other forms already filled out. The forms and the information for specific respondents would be kept on line, like Google keeps emails. The idea is not to create another bureaucratic hurdle for an agency that needs a new form for new information, but a faster way for both the agency and the respondent to make forms and fill them out. This would not be so helpful for Joe the Plumber, but it might save GM some real money. This would also give the President and the public information on what exactly the government collects and how often it is duplicated, as well as what information is truly unique to a particular agency.

The article misses the essential attribute of all these forms including the 152, namely, to keep people employed filling and processing the forms. How can a bureaucracy justify its existence and budget if it does not have documentation for what it does (actually produces). You also forget several other important aspects:
With forms come metrics. Collection and tabulation of the data on the forms. Also, naturally, on the forms themselves (how many have been filed; how many have been processed, etc, etc.)
The information in these Government forms are typically garnered from OTHER forms usually generated by civilian contractors under the direction of government agencies. No Government contract worth its salt would be without a long list of Contract Data Requirements List (CDRL) which ostensebly tell the Government procurement agency what the contractor is doing (which all, natuarlly gets summarized in prenetations and FORMS)

Thank you Mr. Vekert, for actually adding a constructive, thoughtful idea to this “debate.” Bureaucrats only do what we tell them to do, through the imperfect process of lawmaking, so criticizing them may be fun but is useless.

Scientists who receive funds from the NIH under the ARRA are now being advised to participate in training sessions on how to complete the paperwork that tracks how the funds have speeded up progress (see below). Perhaps if there were fewer forms there would be more progress……. But this is merely the thin end of a very thick bureaucratic wedge the NIH has inserted into sensitive parts of scientists’ anatomies over the years. Nowadays, the most important scientific skill is form-filling.
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As was discussed at the recent COGR meeting, OMB has scheduled webinars on various aspects of Recovery Act reporting requirements. You must go to the website and register for each session. Below is the OMB/Recovery Board announcement and link.

Schedule and Registration of Webinars for Recipients Reporting on Recovery Funds is Announced

Wednesday, July 8, 2009

The Office of Management and Budget (OMB) and the Recovery, Accountability and Transparency Board announce that webinars will be held the week of July 20, 2009 to provide information on implementing the guidance set forth in OMB Memorandum M-09-21, Implementing Guidance for the Reports on Use of Funds Pursuant to the American Recovery and Reinvestment Act of 2009 that was released on June 22, 2009.

Each webinar will focus on a major section of the Guidance as well as on the technology solution. The intended audience for these webinars includes Federal agency personnel, prime recipients and sub-recipients.

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